Newell Brands
Vendor Code of Conduct

Newell Brands
Vendor Code ofConduct
Newell Brands and its subsidiaries and affiliates (collectively,“Newell”) are committed to conducting business activities withthe highest standards of business ethics and in accordancewith all applicable laws and regulations. This Vendor Code ofConduct applies to all parties providing goods or services to
Newell and their subsidiaries, affiliates and subcontractors(collectively, “Vendors”), whether organized, operating, or existingunder United States law or the law of any other country, state,political union, municipality, administrative district, or othergovernmental authority. This Code establishes the standard ofconduct Newell expects from our Vendors in a number of areas,including human rights, labor requirements, health and safety,environmental compliance and management practices. Newellwill assess supplier compliance against our Code. Violations of
our Code may result in corrective action, including terminationof the business relationship with Newell.
Newell reserves the right to inspect and/or authorize a thirdparty to inspect and audit, at any time, whether or not noticeis provided in advance, all Vendors and any location wherea good is designed, manufactured, assembled, handled,located, or retailed (“Factories”). Vendors shall also permit
Newell’s customers to inspect and audit its Factories to theextent reasonably required or requested by such customer
as a condition of it doing business with Newell. All such
documentation must be accurate, free from any attempt tofalsify or mislead and made available promptly upon request to
any person of Newell conducting an audit.
All vendors are to notify Newell of any material information thatimpacts Newell Brands reputation or material issues that might
disrupt supplier or a vendors’ ability to produce products orservices per contractual obligations.

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Newell Brands
Vendor Code of Conduct

Zero Tolerance Issues
There are certain violations that Newell Brands deems as “Zero Tolerance.” These types of violations will not be tolerated andwill likely result in termination of our business relationship. All vendors are expected to have effective management systems
and awareness training in place to manage social compliance within their respective factories and to ensure there are no zerotolerance violations present. Vendors must also ensure there are no banned materials from sanctioned countries or regions
present in products sourced to Newell Brands. Vendor must make their factories aware of zero tolerance issues to ensurecompliance with Vendor Code of Conduct requirements.

Newell Brands Zero Tolerance Violation include:• Child Labor• Forced or Prison Labor• Bribery attempts of any form
• Discrimination• Harassment• Corporal Punishment• Unauthorized Subcontracting• Falsified documents• Denial of Access• Circumvention of audit process• Wastewater discharge into the environment without treatment• Contraband Container Contents

In addition to zero tolerance issues, if we find repeat violations or systemic issues in your factory, we may choose to terminate
our business relationship. Our customers may also prescribe additional violations, in which case you may be subject totermination. It is the supplier’s responsibility to ensure they are proactively managing risk and understand the program
requirements of Newell

Compliance With Laws And Regulations
Comply with all applicable laws in any country in which it conducts business and demonstrate actions in all cases that meet orexceed those required by applicable law. The term “applicable law(s)” means with respect to any Vendor, any domestic, foreign,federal, state, local or municipal statute, law, ordinance, policy, guidance, rule, administrative interpretation, regulation, order, writ,injunction, directive, judgment, decree or other requirement of any governmental entity applicable to such Vendor.

Anti-bribery And
Anti-corruption
All Vendors must comply with allanti-bribery and anti-corruption
laws worldwide, and conductbusiness with integrity. Vendors
must never accept or provide
anything of value, either directly
or indirectly, in order to obtain an
improper advantage or to obtain orretain business (e.g money, gifts,meals and transportation). Vendors
must have adequate proceduresin place to prevent bribery in allcommercial dealings undertaken.

Conflicts Of Interest
Vendors must avoid conflicts ofinterest situations. Newell defines a
conflict of interest as being involvedin a relationship or activity thataffects, or has the appearance ofaffecting, your objectivity in making
business decisions in the bestinterest of the company. Vendors
must disclose to Newell any
conflicts of interest situations thatthe Vendor is aware of.

Trade And Customs
ComplianceVendors must comply with allapplicable laws and regulations
related to the exportation andimportation of products. In orderto protect the integrity of cargo
being shipped, Vendors muststrive to comply with supply chain
security processes and proceduresconsistent with U.S. Customs Trade
Partnership Against Terrorism(CTPAT) and other relevant
programs such as Authorized
Economic Operator (AEO).

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Newell Brands
Vendor Code of Conduct

Employment Practices
Newell Brands expects Vendors to respect its employees and, at a minimum, to be compliant with the requirements below.

Wage And Benefits

Working Hours

Child Labor

Wages paid to employees shallbe at least the minimum wage
under applicable law. Paid annual
leave and holidays shall be paid asrequired by applicable law.

Vendors shall comply withapplicable laws and industry
standards with respect to working
hours and must allow to its
employees at least one day off
during each seven-day period.

Vendors shall comply with allapplicable laws and only employ
individuals who are at, or above, thelegal minimum working age or 15years of age, whichever is greater,or, the age designated by applicablelaw for completion of compulsory
education. For jobs that require greater
maturity, are hazardous in nature,require night work or pose a safety risk,these employees are to be a minimumof 18 years of age.

Benefits provided by Vendors
and Factories shall include, at aminimum, those mandated byapplicable law.
For each pay period, Vendor
shall provide its employees anunderstandable wage statement.
Wage deductions must not be
excessive and must be itemized
clearly. Wages are to be paid onschedule at least once per monthor such shorter time period as
required by applicable law.

Should overtime work be necessaryor mandatory, employees are to
be advised with reasonable notice.
Vendors shall pay its employees
overtime pay at a rate which ishigher than regular wages and inaccordance with applicable law.
Vendors shall permit its employees
to take all breaks required byapplicable law and, in any event,reasonable breaks, lunch periods
and bathroom breaks.

Vendors shall maintain official
documentation of each employee’s
date of birth. If this documentation
is not available, they must apply alegitimate and reliable method toassess or confirm each employee’s
age. The minimum working age
requirement is applicable to all subcontracted work performed, in whole orin part, at home or in cottage industries.

Forced Or Indentured Labor & Human Trafficking
Vendors shall not use any prison, indentured, bonded or forced labor. No employees shall be forced to remain employed otherthan on a voluntary basis.
Foreign employees must be employed in full compliance with the labor and employment laws of the host country. The
contract terms under which such employees are employed must be in writing, in a language that the employees canread and understand, and accepted by the employees prior to their departure from their home countries. Fees or costs
associated with the recruitment of workers including but not limited to fees related to work visas, travel costs anddocument processing costs shall not be charged to workers directly or indirectly. Supplier must not withhold the passports
and visas of foreign employees.
Vendors shall maintain and commit to maintaining a work environment that is free from human trafficking. Employment
practices must not include the recruitment, transportation, transfer, harboring or receipt of persons through the use of force orother forms of coercion, abduction, fraud, deception, abuse of power or by giving or receiving payments or benefits to achieve
the consent of a person having control over another person for the purpose of exploitation. Vendors shallnot source any products, components, or materials from suppliers subject to U.S. sanctions or regions with documented
evidence of forced labor and human rights violations.

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Vendor Code of Conduct

Discrimination, Harassment &Disciplinary Practices

Freedom Of Association

Vendors shall not discriminate against their employees
or prospective employees in hiring practices or otherterms or conditions of work on the basis of race, color,
national origin, gender, gender identity, religion, age,disability, political affiliation, sexual orientation, social
or marital status, maternity, or membership in worker’sorganizations, such as unions, or any other similar factors.

Vendors should respect the rights of their employees tochoose whether to associate with any lawful organization
including labor organizations.

Vendors shall not engage in the use or threat of corporalpunishment, the use or threat of any type of abuse orharassment, including mental, physical (including sexual)
or verbal, against its employees or the use or threat of any
other form of intimidation. Vendors shall treat all of its
employees with respect and dignity. All major disciplinary
measures taken against employees shall be documented
by Vendors.

Suppliers must provide their employees with a safe andhealthy working environment, and where provided, a safeand healthy living environment. Suppliers shall comply
with applicable worker safety laws and regulations which
includes:Environmental
Vendors must comply with all applicable environmental
protection laws. Vendors shall have an implemented
environmental management system (EMS) andenvironmental emergency plan (EEP). It is the Vendor’s
responsibility to ensure there is never any illegaldischarge or dumping of waste or wastewater into local
water bodies, including rivers or streams.

Sub-contracting
Factories agree to perform all final manufacturing andassembly operations to produce products, and that they
will not sub-contract the completion or substantiallyall of the manufacturing or assembly of the products
unless Vendor obtains prior written approval from Newell.
Vendors are responsible for notifying Newell of anyplans for change of manufacturing locations. The subcontracting of any work if permitted by Newell, shall notrelieve Vendors from obligations hereunder,
including, but not limited to, the obligation to require thecompanies providing goods and services to Vendors tocomply with this Vendor Code of Conduct.

Health & Safetyo Building Integrityo Occupational Safetyo Occupational Injury &Illnesso Fire Safetyo Emergency
Preparednesso Machine Safeguardingo Chemical Safetyo Sanitation, Food &Dormitoryo Freedom of Movement

Conflict Minerals
Vendors shall implement procedures to assure thatno products or materials supplied to Newell containconflict minerals (columbite-tantalite (also known ascoltan (tantalum, niobium), cassiterite (tin), wolframite(tungsten), gold, cobalt, or their derivatives) that directly
or indirectly finance armed groups through mining or
mineral trading in the Democratic Republic of Congo oran adjoining country. Upon Newell’s request, Vendors
will fully cooperate in responding to any country of origin
inquiries regarding conflict minerals (including requesting
information from its own suppliers); provide requested
documentation; and/or certify its compliance with thisprovision by providing a sworn declaration of one of its
officers, directors, or managing agents.

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Vendor Code of Conduct

Data Security
Vendors are expected to comply with all applicable data security, privacy laws, regulations and retention requirements. Vendors
are expected to ensure they implement and maintain the appropriate administrative, physical and technical controls to protect
confidential information and prevent unauthorized collection, use or disclosure of data.

Monitoring Of The Vendor Code Of Conduct
Newell will review this Vendor Code of Conduct on a regular basis and will revise it to incorporate additional parameters whennecessary. This Code is a general statement of Newell’s expectations with respect to its Vendors. The Code should be read in
conjunction with the Vendor’s obligations set forth in the Responsible Sourcing Manual and in any agreements between Newell(or any of its operating divisions) and the Vendor.
It is the responsibility of the Vendor to ensure that it understands and complies with this Vendor Code of Conduct and to inform
Newell (or a member of its management) if and when any situation develops that causes a Vendor to operate in violation of thisVendor Code of Conduct. Vendors are expected to self-monitor their compliance with this Vendor Code of Conduct, therefore,
Newell strongly encourages Vendors to define and implement a policy for social accountability and to adopt or establish amanagement system to ensure that the requirements of this Vendor Code of Conduct can be met in a consistent manner.
In addition to any other rights Newell may have under any agreement it may have entered into with a Vendor, if Newell determinesthat any Vendor fails to comply with or breaches any terms of this Vendor Code of Conduct or has otherwise behaved in amanner that is inconsistent with the intent of this Vendor Code of Conduct, Newell reserves the right, in its sole and absolute
discretion, to:
1. Terminate the business relationship with the Vendor, including the cancellation of any outstanding purchase orders, or
2. Require corrective actions within an acceptable time period and/or work with the Vendor for an acceptable remedial programin order for the business relationship to continue or resume.

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